Assessing the Need
While visiting a manufacturing client, you discover a noisy and dusty environment. The employees are wearing dust masks and ear plugs, so you assume the facility is in compliance with Occupational Safety & Health Administration (OSHA) regulations. Right?
OSHA’s Stand
Assigning personal protective equipment (PPE) based on perceived hazards is not an acceptable practice according to OSHA. Their Standard 29 CFR 1910.132 requires employers to assess their workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE. Hazards may include impact, penetration, crushing, chemicals, heat, and harmful dust. Employers are required to use feasible engineering and work practice controls to eliminate and reduce hazards before using PPE to protect their employees. Hazard sources can include machinery, high temperatures processes, chemical exposures, grinding or other harmful dust emitting sources, welding, falling objects, sharp objects or tools, and rolling or pinching objects. Typical examples of engineering and work practice controls include ventilation, substitution of the hazardous material, isolation of the work process, rotation of workers, wet methods, and housekeeping. If engineering and work practice controls are not feasible for the work area, then PPE must be used. But caution must be exercised in making this decision, since the use of PPE is typically the last control method that OSHA wants to see utilized.
Assessment and Implementation
If engineering and work practice controls are not feasible for a work area, then the next step is to conduct a full workplace PPE assessment – including evaluation of the work process, identification of workplace hazards, assessment of employee workplace exposure, selection of appropriate PPE, and documentation of PPE efficacy. The components of this assessment are frequently completed during the process of assessing if engineering or work practice controls are feasible.
According to Standard 29 CFR 1910.132, if the assessment helps determine that the use of PPE is necessitated, then OSHA requires:
- Documentation that engineering and work practice controls are not feasible for the work area
- Completion of a full workplace PPE equipment assessment
- Implementation of the recommendations of the assessment
- Documentation of PPE effectiveness
Some of the most common PPE used in workplaces include respiratory protection (dust masks, full-face respirators, etc.), head protection (hard hats), hearing protection (ear plugs or muffs), hand protection (gloves), and foot protection (safety shoes or boots). Through the use of specific materials and design, manufacturers produce PPE to address specific hazards. The selection and use of improper PPE may result in increased risk, exposure, and injuries based on a false perception of protection.
HETI…Helping Assess the Need
Hydro-Environmental Technologies, Inc. (HETI) can assist in assessing workplace and PPE needs. We can provide a workplace PPE assessment – including employee exposure monitoring and area monitoring. Based on the results of this evaluation, we can determine the appropriate PPE for the personnel at the workplace. Once the appropriate PPE has been determined, HETI can develop and conduct effective training to assist in the implementation and assimilation of this control method among the workforce. If a PPE assessment has already been conducted, HETI can help with the evaluation and testing to document the effectiveness of the implemented control methods. It is important to remember that PPE devices alone should not be relied on to provide protection against hazards; but should be used in conjunction with guards, engineering controls, and sound manufacturing practices.